SPECIAL INTERROGATORY NO. 1:
List the last 5 positions you have held in Scientology organizations
and the approximate dates you held these positions. Include time in
the RPF as a "position."
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SPECIAL INTERROGATORY NO. 2:
If you have been in the RPF previously to the above, what dates?
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SPECIAL INTERROGATORY NO. 3:
The following document was recovered in the FBI raid of July 8, 1977
on the Church of Scientology:
INTELLIGENCE SPECIALIST TRAINING ROUTINE - TR L

Purpose: To train the student to give a false statement with good
TR-1. To train the student to outflow false data effectively.

Position: Same as TR-1

Commands: Part 1 "Tell me a lie". Command given by coach. Part 2
interview type 2 WC by coach.

Training Stress: In Part 1 coach gives command, student originates a
falsehood. Coach flunks for out TR 1 or TR 0. In Part 2 coach asks
questions of the student on his background or a subject. Student gives
untrue data of a plausible sort that the student backs up with further
explanatory data upon the coach's further questions. The coach flunks
for out TR 0 and TR 1, and for student fumbling on question answers.

The student should be coached on a gradient until he/she can lie
facily.

***************

If you have been trained on courses using this or similar material,
what dates?
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Were you coached for your testimony against debtor?
Yes_____ No_____
SPECIAL INTERROGATORY NO. 4
Debtor picketed Scientology's operation at Gilman Springs
January 6, 1998.
After that picket you sued debtor to prevent further picketing at
Gilman Springs in the Riverside courts. The case was assigned to
Judge Cunnison and dismissed at the first hearing on a non-suit
motion. Who paid the legal bills for that case?
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SPECIAL INTERROGATORY NO. 5
At the hearing in the above case, you testified for several
pagesthen Judge Cunnison question one of your attorneys, Kendrick
Moxon:

THE COURT: Uh-huh. Okay. And they were posted to the internet,
correct?

MR. MOXON: Yes, Your Honor.

THE COURT: That was the way they were disseminated?

MR. MOXON: Yes. They were posted to the internet, a discussion group
called alt dot religion dot scientology.

THE COURT: Okay.

MR. MOXON: Which is a group frequented by Mr. Hoden and some others.

At the debtor's criminal trial in 2001, you testified as
follows:
Q: For the jury's benefit, what do you mean by "posting"?

A: I'm sorry. Written materials that were put on the internet, and
then they were just printed off. In other words, different types of --
I'm not a computer expert, but just certain things where you can send
e-mail to one another, different people send it, and there's little
news boards where you can put postings, or where you can write and
other people can look at it and add various things to it. And a number
of these things were on there, and they're there for the whole world
to see. In other words, anybody who logs in, I guess, can take a look
at these things. And those were printed off and sent to me, a number
of those regarding Mr. Henson. There was other material, other
documents sent to me regarding Mr. Henson.

"Frequented" would indicate participating or at least reading
on line but the above testimony indicates you only read printouts.
Please explain this inconsistency.
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SPECIAL INTERROGATORY NO. 5:
On May 17, 2000, construction machinery (a paver with no lights) was
moved off the property at Gilman Springs on a public road after dark,
accompanied by a front loader. Ashlee Shaner's car ran into the blade
of the front loader about 9:15 pm, decapitating her almost in front of
her mother.
The next day, May 18, 2000, was a Thursday, "stats" day (when
"production" statistics must be turned in to supervisors). Did the
decision to move this equipment after dark have anything to do with
the next day's being "stats day"?
Yes____ No______
Were you involved at all in the decision to move this equipment after
dark?
Yes_____ No_______
Whether or not you made the decision, did you face discipline for that
decision?
Yes_____ No_______
SPECIAL INTERROGATORY NO. 6:
On May 23, 2000 debtor discussed on private "net chat" picketing
Gold Base over Ashlee Shaner's death.
On May 24, 2000 Scientology attorney Alan E. Oberstein met with the
Riverside County District Attorney Trask regarding possible legal
actions the county could take against the debtor.
Were the two above events connected?
Yes_____ No_______
If not and you know, why did Alan E. Oberstein meet with the
Riverside County District Attorney Trask in regard to debtor?
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SPECIAL INTERROGATORY NO. 7:
May 25, 2000, debtor announced on alt.religion.scientology he would be
picketing the Gilman Springs location over the death of Ashlee Shaner.

May 26, 2000 debtor picketed the Gilman Springs location over the
death of Ashlee Shaner. The location seemed to be deserted. Where
did the order to stay out of view come from?
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SPECIAL INTERROGATORY NO. 8:
May 30, 2000, debtor picketed again, coming upon a chaotic
scene of construction people hurriedly leaving after just starting
work. Debtor speculated at the time that he had been tailed all the
way to Tucson and back. If you know, was he?
Yes___ No____
If no, how were you warned and by whom?

SPECIAL INTERROGATORY NO. 9:
About three weeks before June 25, 2000, a ground squirrel got
into the wires in a transformer vault and was exploded, knocking out
power to part of Golden Era. Did the affected buildings include a
home, office or other facility used by David Miscavige?
Yes____ No______
Were any reports or policies written on preventing a
reoccurrence?
Yes____ No______
Were you involved in any way with such reports or policies?
Yes____ No______
Was a policy of regular inspections of the vaults instituted?
Yes____ No______
Was Stacy Moxon Meyer assigned to the group responsible for
inspection?
Yes____ No______
What was the name of the chief electrician on June 25, 2000?
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SPECIAL INTERROGATORY NO. 10:
June 25, 2000 (Sunday morning), within minutes after Stacy
Moxon Meyer was electrocuted while apparently inspecting a transformer
vault, you and woman PR person approached Barbara Graham and David
Rice, who were picketing, and tried to get them away from the gate by
inviting them to breakfast. This is, by ordinary standards, unusual
behavior. Please explain.
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SPECIAL INTERROGATORY NO. 11:
Were you held responsible in any way for the electrocution
death of Stacy Moxon Meyer?
Yes____ No______
Was anyone else held responsible?
Yes____ No______
SPECIAL INTERROGATORY NO. 12:
July 3, 2000, debtor was accosted on the road that runs
through the Gilman Springs property by private investigator Edwin
Richardson and another person who might have been another private
investigator. Debtor had to jump into the roadway and get motorists
to call the police to escape their aggression. What is the name and
address of the second person? (If licensed, provide also the state
and license number.)
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SPECIAL INTERROGATORY NO. 13:
That second person was caught on tape August 14, 2000
(transcript posted August 18, 2000) threatening debtor's daughter.
What instructions were Edwin Richardson and that other person
(above) given in regard to debtor.

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SPECIAL INTERROGATORY NO. 14:
Debtor was arrested late on July 19, 2000, as a "citizen's arrest" and
then "un-arrested" because you, the complainant, would not sign the
arrest papers. Explain why you would not sign and the circumstances
around this event.
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SPECIAL INTERROGATORY NO. 15:
In debtor's original indictment, Bruce Wagoner, Hilary Dezotell,
Michael Gilchrist, Dana Reid and Muriel Dufresne are named. Why were
these 5 picked from the 735 people you stated worked at the Gilman
Springs property?
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SPECIAL INTERROGATORY NO. 16:
At that time, what were their positions at Golden Era?
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SPECIAL INTERROGATORY NO. 17:
Shortly before debtor's criminal trial, the last three were removed
and you were substituted as a "victim." If you know, explain why the
substitution and who directed that it be done?
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SPECIAL INTERROGATORY NO. 18:
Friday, April 20, 2001, following testimony about your hunting down
debtor's patents, Internet postings, and mention in a multi-person
biographical sketch, you testified under oath at debtor's criminal
trial:
Q: Thank you. Now, the last question that I have for you is this: Why
did you -- why did you go through all the trouble of doing that?

A: Well, I didn't want to make the same mistake again.

Q: What mistake is that?

A: Well, we had an earlier situation where we had what might appear to
be silly or foolish or joking type threats. And as a result somebody
got killed. Somebody got shot. And I didn't want that to happen again.
And I was not going to make that mistake again, and I was determined
not to make it again.

Q: What are you referring to?

A: Referring to the fact that a man one time took a little tiny tank
and wound it up like this, and put a little sign on it and said, "Next
time it will be real." And it chugged through the front door of our
church, of one of our churches.

Q: Where?

A: Portland, Oregon.

Q: Then what happened?

A: All right. We took it to the police, explained to them that this is
a threat. They said there was nothing they could do, looked like just
a joke. He walked in later, shot Helen, who I've known for 25 years,
shot Helen, bullet went through her shoulder, through her baby's head
in her womb . . . ."

Were you aware (at that time) that the bullet was fired not by a
critic of Scientology but by a disgruntled, refund-seeking
Scientologist, Jerius Godeka, and that the bullet did not go through
the baby's head? (" . . . [T]he fetus was unharmed," The Oregonian,
September 26, 1996.)
Yes_____ No_____
Do you now regret your perjury under oath?
Yes_____ No_____
Were you aware at that time that debtor could not refute your
testimony (which he knew to be wrong) because he had been denied
witnesses and was forbidden to speak in his defense?
Yes_____ No_____
SPECIAL INTERROGATORY NO. 19:
Did any of the events of the years 2000 or 2001--deaths,
pickets, trial or related--result in "ethics" actions against you?
Yes_____ No_____
SPECIAL INTERROGATORY NO. 20:
What do you know about the hiring of private investigators in Canada
to "investigate" the debtor?
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